Document mbqYVQV7oVajQm7JJaNX7rkp0

. .SENT BYJ_ XER_0X_Te_l e_c_oj?i_e_r_ 701.7 i. 7_-30,-83 !_ 1M2PM : JU_-20-1993 14!39 FROM * WEIL GOTSHAL & MANGES 2025085706- BRADLEY AND MERRELL# 4 TO P .02 5/12/93 - 5/13/93 FABBI 64 1 A. No, sir* 2 Q. Do you -- are you familiar with an organisation called tha Sdiaonj Electric 4 Institute? 3 A Yes, sir. 6 q . what's the Edison Electric 7 Institute? 8 A* It's an industry association of i 9 investor-owned1elec.tric utilitiesl-t 10 Q. And as far as you know does 11 anyone belong to this organization other than 12 investor-owned utilities? 13 a . i'a not sure. 14 0. What does the group do, as you 13 understand it? 16 A They represent|the industry and 17 provide information to the industry. It's a 18 collecting point and disseminationI otf industry 19 information* They do research, lobby, these kind i 20 of efforts. ! 21 Q. What contact have you had in t 22 your position as safety director wiith BEX over the 23 years? ( 24 A* Most of my contact with EEZ is 25 in annual reports and accident records. LAURIE H. WEBB, LTD. (702) 386-9322 517 South 9th Street, Las Vegas^ Nevada 89101 N IM C ffl-IM E R fllfO iW IM H P U u MWff m ecopier 70171 7-30-83 i 1 : 1 2PM i 3 9 FROM, WEIL COTSHflL & MANGES 2025085786" BRADLEY AND MERRELL!# 5 TO F.03 5/12/93 - 5/13/93 iFABSX 65 1 q . Annual -- whose annual report? 2 A. our company's accident 2 experience providing that information* 4 O- You provide data annually to 5 EEX 7 5 A* Ye/ air. 7 Q< What happen to that data? B a > it' all collected! from all the 9 utilities/ then they publish a report for all of 10 the utilities' ue for comparison purposes* 11 0> Xs it just about accident#? 12 A te/ sir* 13 q . Dote it include information 14 about the cause of the accident? 13 A There is a fatality report 16 that's produced annually that wilIl haIve a short 17 statement about a to the cause of the Injury* IB Q. Does the BEX t!o yoIur knowledge 19 collect information from its members about whether 20 any of their employees have suffered adverse 21 health effects from contact with PCBs? 2 a * if'it were a reportable 23 accident/ it would have shown up jin a report 24 furnished to the E8X* 25 Do you review the report that LAURIE K* WEBB/ LTD* (702) 386-9322 517 south 9th Street# Las Vegas# Nevada 89101 -1993 iJeWcWop* ier 70 17 ; i 7-30-r-^9 3 ;V ' Ti;wi3*P*M# ; 40 FROM L JE IL GOTSHAL & MANGES ro 'M m s jje * BRADLEY AND MERRELL;# P.04 5/12/93 - 5/13/93 * IIFABBJ 1 ESI puts together each year? I 89 2 A Yes, sir. 3 Q. And havt you seen In that 4 report any indication that any member Jutilitles 3 have reported any of their workers suffering adverse health effects from contact with PCBs? 7 A. 2?Ot that 1 recall. The type i 8 information based on that report is a fatality 9 report, and there's never been any -- any as far 10 as I know -- any utility exposure|i of s fatality 11 because of exposure to PCBs unless a capacitor 12 fell on their head i!i 13 Q What's that repiort called that 14 EEX puts out each month? 1. 15 A. I don't recall Ispecifically, ^ 10 but it** called a fatality report 1 i17 Do you know whether other 18 employees of Nevada Power have anyi contacts with 19 the s b i ? I 20 A. Yes, we have other EEI members l| 21 at Nevada Power on different committees, but not 22* from the safety standpoint if that's where you're i 23 going. 24 Q. There is a safeity o1r safety and 25 health committee of EEX? 517 South 9th street, Las Vegas, Nevada 89101